FAQ: Records Destruction Logs and Defensible Destruction

As State agencies continue to sign and return the signature pages adopting the new functional schedule, the Records Analysis Unit has been fielding questions surrounding the content of the signature page. The signature page for functional schedules incorporates a number of aspects of the State Archives of North Carolina’s records management program that were previously communicated in different ways, so this is an excellent opportunity for us to introduce you to them. Over the next few weeks, we’ll take a look at specific provisions in the new signature page and address some frequently asked questions.

For our first post in this new FAQ series, let’s take a look at the following statement under “Destructions”:

For all records with a specified retention period, State agencies must maintain a destructions log as part of the Records Management File.

What, exactly, does this mean? Here are some of the questions on destructions logs that we’ve been asked over the past few weeks.

What is a records destruction log?

A records destruction log is a record that documents when an agency’s records have been destroyed. Ideally, once a record is listed on the destructions log, no copies of that record remain in the agency (including paper and electronic records). A link to a sample destructions log can be found here.

Why is my agency required to maintain a records destruction log?

Records destruction logs are an important component of a records management concept called defensible destruction. Through the creation and implementation of systematic procedures (including following the minimum retention periods on the functional schedules, as well as any longer retention periods established by internal agency policy), agencies can prove their records destructions are part of established business practice. This means that if a public records request comes in for records that have already been destroyed, agencies have a ready answer for why they can no longer provide access to these records, and can prove that the records were destroyed in accordance with approved disposition instructions prior to the request’s arrival. Defensible destruction, combined with prompt access to any responsive records that haven’t been destroyed, increases trust in a public agency’s operations.

Aside from their utility in establishing defensible destruction, records destruction logs also demonstrate that an agency is being efficient and economical with the public’s money when managing its records. It is for these two reasons that destruction logs are considered a best practice in records management.

What does “for all records with a specified retention period” mean?

This refers to all records series listed in the functional schedule that are scheduled for destruction. Some retention periods are specified by the functional schedule itself; others require the agency to establish internal policies setting minimum retention periods. Whether the retention period has been specified by DNCR or by the agency, the records must be included on the destruction log.

Examples of retention periods specified by the functional schedule and via internal agency policy. Both types have a “specified retention period,” so the destruction of the record copy should be logged.

Does this mean I have to make an entry on the destruction log every single time I throw out a slip of paper?

No! The destruction log should be used in conjunction with the other guidance listed on the signature page, including information about record copies, reference copies, and transitory records.

Only the record copy of the record needs to be listed on the destruction log, since the log documents both when a record has met retention and when all copies have been destroyed. Once your office has worked out who is responsible for maintaining the record copy for the full retention period, all remaining copies are designated as reference copies, and can be destroyed when they are no longer useful. Reference copies of records do not need to be listed on the destruction log.

Additionally, transitory records such as “while you were out” slips, fax cover sheets, and working papers for internal, non-policy level documents, can be destroyed once the action these records support has been completed. Transitory records do not have a “specified retention period,” so they also do not need to be listed on the destructions log.

Why is the State Archives of North Carolina requiring a destruction log now?

This provision of the signature page is actually a longstanding practice within the Government Records Section, and it has always been a best practice in records management. The now-superseded General Schedule for State Agency Records had records destruction logs scheduled for permanent retention.

What if the records that I work with are “not public records under G.S. 132”? Do these records also need to be listed on the destruction log?

Yes. Any record made or received in connection with the transaction of public business, regardless of any confidentiality provisions that may exempt it from public inspection, is still a “public record” subject to DNCR’s authority to set retention and regulate destruction under General Statute 121. Destruction logs are a component of that regulated destruction, and are part of the broad “records management program” established in General Statute 121.

How specific does my destruction log need to be?

At a minimum, destruction logs should list the records series, the quantity of records destroyed, the date range of the records, the date they were destroyed, and the authorization for destruction. Regular destructions on an annual or semiannual basis will help limit the number of necessary entries in the log, as (for example) entire fiscal years’ worth of records can be destroyed at one time. Agencies are welcome to be more granular when describing their records, but there’s no need to list records on a file-by-file basis unless individual files are being destroyed on different days.

Example of a destruction log filled out for records destroyed on a State fiscal year basis

Who should be authorized to destroy my records?

The answer to this question should be determined by each agency, depending on agency needs. Some agencies may decide that whoever destroys the record can authorize destruction, while others may require the signature of a manager or records liaison.

What about paper records that have been scanned?

If you’re scanning paper records and want to destroy them before they’ve met their retention period, what you’re essentially doing is designating the electronic record as the record copy, and making the paper original a reference copy. In order to do this, you must have an approved electronic records policy. The electronic records policy and its procedures for scanning should document the workflow for scanning and establish the scanned record as the record copy.

After the policy is in place and approved, destruction of scanned records is managed through the Authorization to Destroy Paper Records form. Since the paper records have been officially designated as reference copies, they can be destroyed without being added to the destruction log. Only the record copy–the electronic version–needs to be listed on the destruction log, once it has met its full retention period.

If you still have questions about destruction logs, please contact the records analyst for your agency, and we’ll be happy to assist you. We hope that, as you begin implementing these logs in your offices, you’ll find it much easier to keep track of your records, and keep destroying them per the schedule, in the future.

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